Rebuttal to Pet Food Industry Response
to Hearings Held April 12, 2007

by Dr. Elizabeth Hodgkins, DVM, Esq.

Today, April 13, 2007, the pet food industry has issued a broadly
published statement and Q & A to counter testimony and questioning
that occurred yesterday in Washington DC before the Agriculture
Appropriations Subcommittee investigating the recent pet food
contamination recalls. Much of what has been published is incorrect
and the industry’s way of trying to do damage control. The
following is the text of the industry’s message and my rebuttals
to that message: (pet
food statements are in italics, my rebuttal in bold):

The pet food industry remains a partner in the investigation
with the FDA and has cooperated with state and federal regulators
since evidence leading to the recall first surfaced. The industry
will continue cooperate fully with any other official investigations
relating to this incident.

The FDA’s investigation is ongoing and has not reached
any conclusions about how any foreign substances entered the process.
I think it’s presumptuous to additional regulatory measures
at this time. Only when we have this information can we make an
accurate and informed decision.

The industry representative insisted that the industry
is cooperating fully in this investigation, yet when asked how
long it had taken Menu Foods to report to the FDA about the toxins
in their food, he admitted that he did not know. The time to report,
which is well documented at 3 weeks, would have been something
he would have known had the industry been fully involved and cooperating
with this investigation. The industry wants this to go away, not
be fully investigated so that better quality control measures
can be implemented.

How Pet Foods Are Regulated

Pet foods are one of the most highly regulated food products.
They are required by law to provide on their labels more information
than most human foods. State departments of agriculture provide
standards and enforcement policies for regulation of manufacture
of pet foods resulting in safe foods. Ingredients in pet food
must be acceptable to state authorities. In the March 23 press
conference Sundlof also stated that regulation of pet foods is
the same as human foods.

Pet foods are far from regulated as human foods are.
4D meat (meat from dead, dying, diseased or disabled animals)
CANNOT be used for human food, but it CAN be used in pet foods
and is used routinely by at least some manufacturers. Other ingredients
that would not be allowed in human foods, such as rendered tissues,
are allowed in pet foods. Further, human food health claims are
very difficult for human food makers to get. Virtually ALL pet
foods contain unsubstantiated claims for safety, completeness
and balance that NO HUMAN FOOD in the world would ever be able
to get. While some pet foods are likely to be adequate food for
pets, many are not, yet there is no testing done to differentiate
the good from the bad in this self-regulated industry. FDA has
delegated the responsibility of pet food regulation to an association
known as AAFCO. AAFCO itself ADMITS it has NO regulatory AUTHORITY
or enforcement capabilities, so although there are several layers
of APPARENT regulation, there is actually no regulation of pet
foods today.

Pet food manufacturers are responsible for producing safe
products. The U.S. Food and Drug Administration and state governments
provide the rules, guidance and oversight under which safe pet
food is produced. FDA requires pet food to be wholesome, contain
no harmful or deleterious substances, and to be truthfully labeled.

Yes, pet food companies are responsible for producing
safe products, and they have failed many times in the past, at
least 3 times in the past 18 months. To say they are responsible
for doing something is quite different from saying they are ACTUALLY
doing it. The facts speak for themselves on this point. The pet
food industry has breached the FDA’s mandate of them because
they are self-regulated!

This is an untruth. Many if not most pet food ingredients
undergo no testing whatsoever. If this statement were true, we
would not have repeated pet food aflatoxin toxicity problems as
we do. We also would not have had a recent and very serious toxicity
problem in a major pet food from excess Vitamin D supplementation.
This statement merely describes what is SUPPOSED to happen, not
what really DOES happen. The facts speak for themselves.

A Consumer's Guide to Pet Food: Valuable Information for
Pet Owners

Veterinarians agree that pets are living longer, healthier
lives since the use of commercially prepared pet foods became
widespread. Decades of research have gone into the development
of pet food to make sure the special nutrition needs of pet dogs
and cats are met.

Veterinarians DO NOT agree about this, they can’t,
it is totally unproven. Evidence about changes in the life span
of pets over the past several decades is sparse, and no scientist
would dare draw the conclusion that pets today live longer on
average than pets 30-40 years ago because of commercial pet foods,
for example. What does seem clear is that today’s indoor
pets live much longer than those that live outdoors. The evidence
for this conclusion is strong.

Those who would give commercial pet food even partial
credit for this increase in life expectancy in the indoor pet,
however, have absolutely no evidence to back up this conclusion.
There are many factors that affect the life span of pet animals
under indoor and outdoor circumstances. Indoor pets are more protected
from death due to automobiles and predators, they are more protected
from exposure to infectious disease and often receive more medial
care than outdoor pets, to name just a few of the important differences
between these two groups. It is easy to sweep commercial food
consumption right along with all of these other factors as contributing
to longer life in today’s pets. Unfortunately for this particular
factor, there is no reason to believe it has anything to do with
the longer life of house pets. Let’s look at an analogy
to understand how this might be so.

Humans in the US enjoy longer life expectancy today than
they did fifty years ago. During those decades of improving average
life span, those same people have consumed ever-increasing amounts
of fat-laden, sugary, carbohydrate-rich “fast” food
and other types of over-processed “convenience” foods.
We are far more obese today than in decades past, and human nutritionists
nag us endlessly about changing our diets to include better quality,
fresh whole foods. Imagine anyone believing that this increasing
consumption of highly processed “fast” foods and increasing
obesity is the reason, or even makes a positive contribution to
our increasing life spans! We are living longer in spite of our
diets, not because of them. Many other factors, such as less tobacco
smoking, the use of seatbelts, better prenatal and postnatal care,
and astonishing high-tech medical advancements for defeating disease
and injury account for our increasing life spans. Our convenience-oriented
diets are actually working against longer life, but cannot defeat
all of these other strong protective factors in our lives.

So it is with our pets. When they live indoors, they
live longer than if they lived outdoors, but commercial foods
likely have no part in adding those extra years. Like our own
“overprocessed” diets, they may even be depriving
our pets of even greater health and longevity. If you hear anyone
make the flat statement that pets are living longer BECAUSE of
commercial foods, demand to see the scientific data for that statement!

Question
What does "complete and balanced" mean?

Answer
Unlike most foods for people, many pet food products are designed
to be the sole source of nutrition for a pet dog or cat. Products
that are labeled "complete and balanced," as defined
by the Association of American Feed Control Officials (AAFCO),
have been tested to make sure they meet the complex nutritional
requirements of a healthy dog or cat.

No, they have NOT been tested to make sure they meet
the requirements of healthy pets! Only a very few “sample”
diets have even been tested on any animals for even 6 months.
Considering that cats have a natural lifespan of 20 years or more,
and dogs can live 10-20 years depending on breed, 6 months is
NOT long enough and 6 animals is not anywhere close to a statistically
valid number to even prove a 6 month claim. This is one of the
most serious and most misleading of the untruths that pet food
companies make about their foods.

Question
What does it mean on a pet food label that a product has been
tested using animal feeding trials?

Answer
There are two ways a pet food company can test the nutrition of
its products. One method is the use of standardized animal feeding
trials, designed by the Association of American Feed Control Officials
(AAFCO), to make sure their products meet the complex nutritional
requirements of dogs and cats. The animals in these tests are
fed the food for six months and are closely monitored to make
sure they stay healthy. A product using this test will have language
similar to the following on the label - "Animal feeding tests
using AAFCO procedures substantiate that Nancy's Food for Dogs
provides complete and balanced nutrition for all life stages."

This is almost a completely truthful answer, because
it admits that this “study” only last six months.
This answer omits two important factors: there are only a handful
of animals tested, and only a few sample diets are even tested
on those few animals for those few months.

Question
Are fillers used in pet food?

Answer
Every ingredient used in pet food is there for a reason. Decades
of research have gone into making pet foods that meet the nutritional
needs of dogs and cats. The makers of pet food do not put in anything
that's not needed.

There is almost no research on any pet food anywhere
that can be considered scientific by any genuine scientist. Whether
reused vegetable oil and rendered animal scraps and wood cellulose
is “needed” by any dog or cat is very highly questionable
by intelligent and well trained experts. The cat has absolutely
no need for carbohydrates, for example, yet all dry cat food has
PLENTY of this cheap ingredient that is required for dry food
processing. Further, the acids that pet food companies put into
“urinary tract diets” can and do even cause other
diseases, proving that those acidifiers are not only not needed,
but are even harmful to many cats. Pet food companies absolutely
DO put things in pet food that are not needed and that can even
cause harm.

Question
What is ingredient "splitting?"

Answer
Some people incorrectly believe pet food makers split up ingredients
to give the illusion that some ingredients are at higher concentrations
than others. Pet food makers are required to carefully label their
products according to stringent government regulations. Just as
the case with food for people, pet foods must clearly state what
ingredients are included in the product. Each ingredient in pet
food is there for a reason and to serve a nutritional purpose.

The "stringent" ingredient regulations have
been developed by the industry in concert with AAFCO. AAFCO has
no real authority over the pet food companies, and goes along
with the desires of an industry that, by the admission of the
FDA, is a good way for by-products of American agriculture to
“dispose” of those by-products of agriculture that
are not fit for or undesirable for humans to eat. Many ingredients
in pet food serve no nutritional purpose in our pets, but keep
farmers and ranchers from having to throw them away.

An example of ingredients splitting: Pet food companies
who wish to disguise the amount of cereals in their products will
list several different cereals in stead of using just one (not
top quality cereals either) so that what meat IS in their products
will legally be listed as the one of the first ingredients. In
many, if not most of these foods, cereal actually makes up the
majority of the food, but consumers see “chicken”
as one of the top 2-3 ingredients and think that chicken is a
predominant component of the food. This is “smoke and mirrors.”

The regulations may demand that the ingredients be listed
in order of predominance, but there is NO prohibition against
the sleight of hand described in this example.
The pet food industry is an ineffectively regulated 15 billion
dollar industry that produces everything your pet eats, day in
day out. This should make you want to know a lot more about what
is going into those cans and bags, and into your pet!

Contrary to the assertions of some, it simply is not in the
best interest of companies to want to sell potentially unsafe
product. The long history of the industry's provision of safe
and nutritious products to the consumer speaks to its dedication
to the health and well-being of pets.

This is almost as stupid a statement as the "pets
are living longer because of commercial foods" lunacy. The
ACVN apparently thinks this comment is a winner for them and I
hope pet owners have the sense to see through it. The makers of
Vioxx, and the makers of Peter Pan peanut butter hve no interest
in having dangerous products either, but does that mean those
contaminations did not happen or were not extremely serious, and
were not the result of mistakes made by the givernment and the
companies themselves?? Are you any less dead if Vioxx was only
negligently or accidentally unsafe than if Meriel inteneded for
you to die from use of it? Do companies have to WANT pets and
people to die for toxic problems to be held against them? Isn't
negligence and indifference enough? I'm an attorney and I can
tell you that negligence and indifference certainly IS enough
to win a lawsuit, and it certainly ought to be enough for the
court of public opinion!

Further, there is NO SUCH long history of safety. Within
the past decade, no fewer than 10 incidences of tainted, leathal
pet food have been uncovered, and those are only the cases that
were uncovered! How many more have not been recognized and exposed
to the public??

The pet food industry, and even more so the expert "apologists"
for the industry like the "College of Veterinary Nutrition"
should be ASHAMED of themselves. They are defending the indefensible,
making them no better, not one tiny bit better, than the poorest
quality, most negligent sloppy pet food company!

How can we expect the pet foo companies to behave well
when this is the way the specialists behave??????????